☢ test - Í

S.E.2d 828 (holding that the defendant's crime at the time of his arrest of aggravated assault against a peace officer was directly related to the original crimes …). See also Williams v. State, 277 Ga. 368, 369 & n. 8(3), 589 S.E.2d 563 (2003) (holding that the defendant had not received ineffective assistance of counsel based on counsel's failure to move to sever a disorderly conduct charge that occurred at the time of arrest on the original homicide crime, stating that joinder of two crimes is proper ‘when one crime is a circumstance of the arrest on the other crime,’ …).” Distinguishing Benford v. State, 272 Ga. 348(3), 528 S.E.2d 795 (2000) (circumstances of arrest may not be admissible “where the evidence is wholly unrelated to the charged crime, the arrest is remote in time from the charged crime, and the evidence is not otherwise shown to be relevant....”). Benford didn’t involve a severance motion, but in any event allowed in evidence of cocaine possession at time of arrest “given the role crack cocaine played in the events leading up to the murder of the victim.” Madison v. State, 329 Ga.App. 856, 766 S.E.2d 206 (November 20, 2014). Child molestation convictions affirmed (but sexual battery and aggravated sexual battery convictions reversed based on improper jury charge); no error in declining to sever charges arising out of multiple incidents occurring over several years against same victim. “[W]here, as here, ‘the offenses involve an ongoing scheme involving the same type of crime against the same victim,’ a motion to sever may be denied. Bolton v. State, 258 Ga.App. 581, 582–583(1), 574 S.E.2d 659 (2002).” Algren v. State, 330 Ga.App. 1, 764 S.E.2d 611 (November 10, 2014). Statutory rape conviction affirmed; no error in joining statutory rape indictment for trial with second indictment charging child molestation against a different victim. Charges would have been admissible as similar transactions in separate trials; charges and evidence weren’t so numerous or complex as to confuse the jury. “Indeed, the verdict itself, including Algren's acquittal for the two child-molestation charges, shows that the jury fully understood the law and evidence.” Ray v. State, 329 Ga.App. 5, 763 S.E.2d 361 (September 4, 2014). Conviction for multiple counts of rape and related offenses, arising from three separate incidents, affirmed; trial court properly denied motion to sever. “As a general rule, where the evidence of the other crimes would be admissible as similar transaction evidence at trial, ‘or where the similarity of the offenses manifests a pattern, the trial court does not abuse its discretion in denying the motion for severance.’ (Citation and punctuation omitted.) Id. Although a defendant has a right to sever multiple offenses if they are joined solely because they are of a similar character, ‘offenses have not been joined solely because they are of the same or similar character when evidence of one offense can be admitted upon the trial of another, i .e., when they are so strikingly similar as to evidence a common motive, scheme or bent of mind.’ (Citation and punctuation omitted; emphasis in original.) Green v. State, 291 Ga. 287, 289(2), 728 S.E.2d 668 (2012). … Here, although the crimes in the present case occurred at different times and different locations and involved different victims, they were connected by more than just their similar character. The charges against appellant clearly show a recurring pattern of conduct suggesting a common scheme or modus operandi. Green, supra at 290(2), 728 S.E.2d 668. The victims of the three sexual assaults were adult women between the ages of 23 and 38 years old, none of the women knew Ray, all three incidents occurred in DeKalb County within 6 months of each other, each victim was taken by vehicle to a secluded location before they were raped, all three incidents involved a handgun, and semen matching Ray's DNA profile was found on each victim.” Cupe v. State, 327 Ga.App. 642, 760 S.E.2d 647 (June 19, 2014). 1. Robbery and burglary convictions affirmed; no severance required where items taken in both incidents were found at the same time and place, in a car parked at defendant’s home. “Thus, the two crimes were intertwined such ‘that some of the same evidence would be required at separate trials on each charge.’ Johnson v. State, 257 Ga. 731, 733(2)(c) (363 S.E.2d 540) (1988) (citation and punctuation omitted). See Moment v. State, 157 Ga.App. 40, 41 (276 S.E.2d 97) (1981) (finding no error in failing to sever the charges for trial where ‘[t]he evidence of identity, though relating to different victims, was inextricably intertwined in all the various offenses charged’ and that ‘it would be almost impossible to present to a jury evidence of one of the crimes without also permitting evidence of the others’) (punctuation omitted).” 2. Also, charges related to threats made to arresting officer were properly joined with the robbery and burglary. “‘[E]vidence of an act by an accused, intended to obstruct justice or avoid punishment for the crime for which he or she is on trial, is admissible if the act constitutes an admission by conduct.’ Moss v. State, 245 Ga.App. 811, 813(2), 538 S.E.2d 876 (2000) (citations and punctuation omitted). See, e.g., Dukes v. State, 290 Ga. 486, 488(3) (722 S.E.2d 701) (2012) (evidence of a defendant's attempt to influence or intimidate a witness can serve as circumstantial evidence of guilt).” Graf v. State, 327 Ga.App. 598, 760 S.E.2d 613 (June 17, 2014). No error in joining for trial defendant’s charges of arson and drug possession. “Evidence of Graf's drug habit was admissible to prove her motive for burning down her own insured house, and the evidence and law of drug possession ‘was not so complex or confusing as to require ... severance.’ Wilcox v. State, 271 Ga. 544, 546(2), 522 S.E.2d 457 (1999) (citations omitted).”